Remarks. Met with Sonia Parham (Safety) during the inspection. Ms. Parham walked the facility grounds with me.

Transcription

1 NPDES Industrial No-Exp. Storm Water AFIN: Permit #: ARR00A572 Form Approved OMB No Approval Expires UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Washington, D.C NPDES Compliance Inspection Report Section A: National Data System Coding Transaction Code NPDES Yr/Mo/Day Inspec. Type Inspector Fac. Type 1 N A R R 0 0 A C 19 S Remarks Inspection Work Days Facility Evaluation Rating BI QA Reserved N 72 N Section B: Facility Data Name and Location of Facility Inspected (For industrial users discharging to POTW, also include POTW name and NPDES permit number) Stark Manufacturing, LLC 310 Pennington Dr, Paris, AR Entry Time/Date 1000/ 3/12/12 Exit Time/Date 1030/ 3/12/12 Permit Effective Date 6/8/10 Permit Expiration Date 6/30/14 Name(s) of On-Site Representative(s)/Title(s)/Phone and Fax Number(s) Sonia Parham/ Safety/ Note: Mike Koehler is on permit but no longer with company. Name, Address of Responsible Official/Title/Phone and Fax Number Sonia Parham/ Safety/ Note: Mike Koehler is on permit but no longer with company. 310 Pennington Dr, Paris, AR Yes Contacted No Other Facility Data PDS# Section C: Areas Evaluated During Inspection (S = Satisfactory, M = Marginal, U = Unsatisfactory, N = Not Evaluated) S Permit N Flow Measurement N Operations & Maintenance N Sampling N Records/Reports N Self-Monitoring Program N Sludge Handling/Disposal N Pollution Prevention N Facility Site Review N Compliance Schedules N Pretreatment N Multimedia N Effluent/Receiving Waters N Laboratory M Storm Water N Other: Section D: Summary of Findings/Comments (Attach additional sheets if necessary) Met with Sonia Parham (Safety) during the inspection. Ms. Parham walked the facility grounds with me. One waste cardboard dumpster and one scrap metal dumpster un-covered (Also additional empty dumpster un-covered). Solids were on the ground near a dock (possibly metal dust/blasting material). Name(s) and Signature(s) of Inspector(s) Travis Harmon Agency/Office/Telephone/Fax Arkansas Department of Environmental Quality / Russellville / x 14 / Date Signature of Reviewer Agency/Office/Phone and Fax Numbers Date

2 NPDES Industrial No-Exp. Storm Water AFIN: Permit #: ARR00A572 No Exposure Exclusion Verification Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future? Answering Yes to any of these questions indicates the facility is not eligible for the No Exposure Exclusion. a. Using, storing, or cleaning industrial machinery or equipment, and areas where residuals from using, storing, or cleaning industrial machinery or equipment remain and are exposed to storm water. Y N b. Are materials or residuals on the ground or in storm water inlets from spills/leaks. Y N metal dust or blast material on ground near loading dock. c. Are materials or products from past industrial activity exposed. Y N d. Is material handling equipment exposed (except adequately maintained vehicles). Y N e. Are materials or products during loading/unloading or transporting activities exposed. Y N f. Materials or products stored outdoors (except final products intended for outside use [e.g., new cars] where exposure to storm water does not result in the discharge of pollutants). Y N g. Materials contained in open, deteriorated, or leaking storage drums, barrels, tanks, and similar containers. Y N h. Materials or products handled/stored on roads or railways owned or maintained by the discharger. Y N i. Waste materials exposed (except waste in covered, non-leaking containers [e.g., dumpsters]). Y N Un-covered dumpsters during inspection (3: 1 cardboard, 1 scrap metal, 1 empty). j. Application or disposal of process wastewater (unless otherwise permitted). Y N k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not otherwise regulated (i.e., under an air quality control permit) and evident in the storm water outflow. Y N General Inspected 3/12/12. Met with Sonia Parham (Safety) during the inspection. Ms. Parham walked the facility grounds with me. Violations: (b) One waste cardboard dumpster and one scrap metal dumpster un-covered (Also additional empty dumpster uncovered). (i) Solids on ground near dock (possibly metal dust/blasting material). Other: Pallets stacked outside. I did not see any obvious contaminants on the pallets at the time of inspection. The facility should inspect pallets and store any dirty or contaminated pallets under cover.

3 March 19, 2012 Sonia Parham Stark Manufacturing, LLC 310 Pennington Dr. Paris, AR AFIN: NPDES Permit No.: ARR00A572 Dear Ms. Parham: On March 12, 2012, I performed a routine compliance inspection of the waste water treatment facility in accordance with the provisions of the Federal Clean Water Act, the Arkansas Water and Air Pollution Control Act, and the regulations promulgated thereunder. This inspection revealed the following violations: 1. Un-covered waste dumpsters in use at the facility. Some solids on the ground. This conflicts the requirements of No exposure (Part I, 1.8). One waste cardboard dumpster and one scrap metal dumpster un-covered (Also additional empty dumpster un-covered). Solids were on the ground near a dock (possibly metal dust/blasting material). All dumpsters should be covered or located under cover to prevent materials from coming into contact with storm water. Spilled materials should be cleaned up using dry methods. This response should be mailed to the address below, or ed to Water-Enforcement- Report@adeq.state.ar.us. This response should contain documentation describing the course of action taken to correct each item noted. This corrective action should be completed as soon as possible, and the written response with all necessary documentations (i.e. photos) is due by March 30, For additional information you may contact the Enforcement Branch by telephone at or by fax at Other comments: The facility has pallets stacked outside. I did not see any obvious contaminants on the pallets at the time of inspection. The facility should inspect pallets and store any dirty or contaminated pallets under cover. If I can be of any assistance, please contact me at harmont@adeq.state.ar.us or at extension 14. Sincerely, Travis Harmon District 5 Field Inspector Water Division cc: Water Division Enforcement Branch Water Division Permits Branch

4 From: To: Subject: Date: Attachments: Sawyer, Sam Allen-Daniel, Leslie FW: Response to AFIN: Friday, March 30, :57:20 PM CAR2042.pdf CAR 2041.pdf Training record.pdf From: Sent: Friday, March 30, :35 PM To: Water-Enforcement-Report Cc: Subject: Response to AFIN: NPDES Permit No.: ARR00A572 Below are the corrective actions taken for the No Exposure Exclusion Verification findings from a routine compliance inspection on 3/12/12. b. metal dust or blast material on ground near loading dock - Corrective Action, i. un-covered dumpters during inspection (3: 1 cardboard, 1 scrap metal, 1 empty) - Corrective Action,, Please contact me if you have any questions. God bless and keep you, Sonia Parham Safety/Training Coordinator Stark Mfg LLC 310 Pennington Dr Paris, AR ext When one door closes another door opens; but we so often look so long and so regretfully upon the closed door, that we do not see the ones which open for us. ~Alexander Graham Bell~

5 Corrective Action Report: CAR Number: 2041 CAR Open Date: 03/27/2012 Opened By Sonia Parham Source: Internal Audit (check one) System Non Conformance Part Non Conformance Management Review Issue Customer / 3rd Party Non Conformance Safety Issue Environmental Issue Assigned To: Karin Anhalt Status: Closed Response Due04/10/2012 Revised Due date 04/10/2012 Department: Materials CAN or NCR Ref. No. Element: DESCRIBE THE PROBLEM: If problem is product related then list FULL Customer Part Number & Cell Number here P.N. / Cell # / Problem Category: Defects: out of PROBLEM Uncovered dumpsters during ADEQ inspection ( 1 cardboard, 1 scrap metal, 1 empty) 1. CONTAINMENT ISOLATE & CONTAIN SUSPECT PARTS Link to DMA record, if appropriate to CAR --> 2. PLAN (Root Cause Analysis) Step 1. Restate the problem Step 2. Using brainstorming rules, list as many causes as possible under the various categories without discussion. Step 3. Once all possible sources are exhausted, discuss the various causes Step 4. Determine the 3 most likely (various voting methods available). Number them in order of importance (1 is the most likely cause) Restate the Problem in simplest terms possible > Materials Manpower Methods Machines

6 DESCRIBE THE ROOT CAUSE OF THE PROBLEM: Employees did not have a clear understanding of what is acceptable/not acceptable environmental practices. Train employees on acceptable/not acceptable environmental practices. Put tarp over cardboard scrap bin, to protect from rain Remove empty metal bin from premises Store scrap metal bin under the awning, out of the weather at shipping dock area 3. DO DETERMINE & IMPLEMENT THE BEST SOLUTION: Reminder: Be sure to consider the use of Mistake Proofing Methods as a means to prevent recurrence. Train employees Place tarp on cardboard bin Schedule pick up and removal of empty metal bin Move scrap metal bin under awning 4. CHECK EVIDENCE OF ACTION TAKEN: Training accomplished on 3/20/12 Tarp put on cardboard collection bin

7 Scrap metal bin, under the awning Empty metal bin no longer on premises EVIDENCE OF EFFECTIVENESS 5. ADJUST IS THE SOLUTION EFFECTIVE OR SHOULD OTHER STEPS BE TAKEN.? SHOULD THIS SOLUTION BE APPLIED TO CROSSLINE ACTIVITIES?

8 Auditor: Sonia Parham/STARKMFG Scheduled for follow up audit on - Findings: CAR CLOSED This CAR is closed when signed by one of the following: Date Signed Manufacturing Mgr. Quality Director 03/29/2012 Electronically Signed By: Gloria Kessler/STARKMFG

9 Corrective Action Report: CAR Number: 2042 CAR Open Date: 03/27/2012 Opened By Sonia Parham Source: Internal Audit (check one) System Non Conformance Part Non Conformance Management Review Issue Customer / 3rd Party Non Conformance Safety Issue Environmental Issue Assigned To: Andrew Welch Status: Open Response Due04/10/2012 Revised Due date 04/10/2012 Department: Production CAN or NCR Ref. No. Element: DESCRIBE THE PROBLEM: If problem is product related then list FULL Customer Part Number & Cell Number here P.N. / Cell # / Problem Category: Defects: out of PROBLEM Metal dust or blast material on ground near loading dock 1. CONTAINMENT ISOLATE & CONTAIN SUSPECT PARTS Link to DMA record, if appropriate to CAR --> 2. PLAN (Root Cause Analysis) Step 1. Restate the problem Step 2. Using brainstorming rules, list as many causes as possible under the various categories without discussion. Step 3. Once all possible sources are exhausted, discuss the various causes Step 4. Determine the 3 most likely (various voting methods available). Number them in order of importance (1 is the most likely cause) Restate the Problem in simplest terms possible > Materials Manpower Methods Machines

10 DESCRIBE THE ROOT CAUSE OF THE PROBLEM: At end of the day, sand blasting filters are blown out, outside of building. The blasting process is taking carbon off of parts. Inside - Swept up sand blasting medium is collected in a tub, with no specified disposal instruction. Sweep up blasting medium outside, from filters, and store in plant until confirmation of disposal is made. Define disposal instruction and train employees. 3. DO DETERMINE & IMPLEMENT THE BEST SOLUTION: Reminder: Be sure to consider the use of Mistake Proofing Methods as a means to prevent recurrence. The outside area has been cleaned. A metal drum has been placed in the sand blast area for used medium and cleaning of filters. Disposal options are being investigated with Safety Kleen and local Environmental reps. 4. CHECK EVIDENCE OF ACTION TAKEN:

11 before

12 after medium Collection for blasting

13 EVIDENCE OF EFFECTIVENESS 5. ADJUST IS THE SOLUTION EFFECTIVE OR SHOULD OTHER STEPS BE TAKEN.? SHOULD THIS SOLUTION BE APPLIED TO CROSSLINE ACTIVITIES? Auditor: Sonia Parham/STARKMFG Scheduled for follow up audit on - Findings: CAR CLOSED This CAR is closed when signed by one of the following: Manufacturing Mgr. Quality Director Date Signed Electronically Signed By:

14 Attendance & Competency Record Course Name: Environmental Policy, Regulations and Procedures - refressher on keeping collection bins covered outside or out of the weather. Date: 03/20/2012 Length:.17 Hrs Course Instructor: Karin Anhalt Type: OJT Trainees Who attended: Who proved competent: (as defined in course outline) Tim Harkey; Andy Trusty; Tony Williams; Gomer Cummins

15 April 9, 2012 Ms. Sonia Parham Stark Manufacturing, LLC 310 Pennington Dr. Paris, AR RE: AFIN: NPDES Permit Tracking No.: ARR00A572 Dear Ms. Parham: The Department has received your response to the March 12, 2012 inspection of your facility by our District Field Inspector, Travis Harmon. Your letter appears to satisfy the discrepancies identified during the visit. The Department expects that the corrective actions taken will be maintained to ensure consistent compliance with the requirements of the permit. Acceptance of this response by the Department does not preclude any future enforcement action deemed necessary at this site or any other site. The Department will keep the inspection and response on file. If future violations occur that require enforcement action, the Department will consider the inspection and response as required by the Pollution Control and Ecology Commission Regulation No. 7, Civil Penalties. This regulation requires the Department to consider the past history of your site and how expeditiously the violations were addressed in determining any civil penalty that may be necessary for any future violations. If we need further information concerning this matter, we will contact you. Thank you for your attention to this matter. Should you have any questions, feel free to contact me at or you may me at Sincerely, Amy Schluterman Enforcement Analyst Water Division Enforcement Branch